Insider Trading Policy

ITMF prohibits insider trading and strictly enforces and monitors compliance with its policy on insider trading, which covers ITCO transactions by its officers, directors, employees, and subsidiaries.

If an officer, director or any employee of the Company has material, nonpublic information relating to the Company, it is the Company’s policy that neither that person nor any related person, may buy or sell ITCO or engage in any other action to take advantage of, or pass on to others, that information.

To avoid even the appearance of impropriety, additional restrictions on trading ITCO apply to directors and members of executive management.

The Company has adopted this policy to avoid damage to its reputation for integrity and ethical conduct. We all strive to establish a reputation for observing the highest standards of conduct, even the appearance of improper conduct must be avoided.